Ecology Report

PROPOSED RESIDENTIAL SCHEME J Breheny Works Site, Flordon Road, Creeting St Mary,Suffolk

February 2021

REPORT PRODUCED BY: MHE Consulting Ltd Mill House Homersfield Harleston IP20 0ET

01986 788791 07766 771305 [email protected]

ARCHITECTS: Nick Comer Wincer Kievenaar Architects Market Place Hadleigh Suffolk IP7 5DN

01473 827992 07900 917567 E:[email protected]

Contents Amendment Record REPORT NUMBER: BREHENY/2021/ER/001

This report has been issued and amended as follows:

Issue Revision Description Date Signed

1 0 Draft report issued for comment 05/02/21 C. Whiting

This report has been prepared in accordance with the instructions of the client for their sole and specific use. Any other persons who use any information contained within do so at their own risk.

Contents

EXECUTIVE SUMMARY 1 INTRODUCTION 1 1.1 BRIEF 1 1.2 SITE LOCATION AND DESCRIPTION 1 2 PLANNING POLICY AND LEGISLATION 2 2.1 INTRODUCTION 2 2.2 PLANNING POLICY 2 2.3 LEGISLATION 3 3 METHODOLOGY 6 3.1 INTRODUCTION 6 3.2 DESK SURVEY 6 3.3 FIELD SURVEY 6 3.4 SURVEY CONSTRAINTS 8 3.5 SURVEYORS 8 3.6 ASSESSMENT 8 4 RESULTS 9 4.1 INTRODUCTION 9 4.2 BASELINE ECOLOGICAL CONDITIONS - DESK STUDY 9 4.3 BASELINE ECOLOGICAL CONDITIONS – FIELD SURVEY 11 4.4 GEOGRAPHIC CONTEXT 14 5 ASSESSMENT AND RECOMMENDATIONS 15 5.1 INTRODUCTION 15 5.2 DESCRIPTION OF PROPOSED DEVELOPMENT 15 5.3 FURTHER SURVEYS REQUIRED 15 5.4 ASSESSMENT OF IMPACTS 15 5.5 HABITATS AND VASCULAR PLANTS 16 5.6 AMPHIBIANS AND REPTILES 16 5.7 BATS 17 5.8 NESTING BIRDS 19 5.9 OTHER S. 41 LIST HABITATS AND SPECIES 19 5.10 COMPENSATION 20 5.11 CUMULATIVE EFFECTS 20 5.12 ENHANCEMENT OPPORTUNITIES 21 5.13 CONCLUSIONS 22 6 REFERENCES 23

Figures Figure 1 Application site location plan Figure 2 Phase 1 habitats plan Figure 3 Ponds location plan

Appendices Appendix A1 Photos Appendix A2 EcIA Criteria Appendix A3 Hedgerow specifications Appendix A4 Bird boxes Appendix A5 Bat box

Executive Summary

MHE Consulting Ltd were instructed to undertake an ecological survey and assessment of a proposed residential development of the J Breheny works site, Flordon Road, Creeting St Mary, Suffolk (TM 09471 55528) where planning approval (Ref: 4188/15) was previously granted (08/04/16) for a hybrid residential (52 units) and commercial (training facility, workshop and car parking) scheme.

A new application is to be submitted for a residential scheme (19 units: 14 affordable and 5 open market) within the area previously approved for a training facility, workshop and car parking area. A minor amendment to the approved residential scheme (reduction in units to 51) together with the proposed residential scheme will result in a total of 70 dwellings on site, with 24 affordable units.

The site comprises the main depot of the J Breheny civil engineering company and includes numerous workshops, storage buildings, and hard standing areas. A scrub and tree covered embankment exists along and beyond the eastern and southern site boundaries.

None of the buildings support evidence of notable nesting birds, though small passerines could potentially nest. Area of scrub and trees along embankments adjacent to the eastern and southern site boundaries provide potential nesting, song perch and foraging habitat for a range of bird species.

No bat roosting features, or evidence of roosting bats was found in any of the buildings present on site. The scrub and trees on the embankments adjacent to the site provide moderate suitability as bat commuting and foraging habitat, with habitat also suitable for use by common amphibians (e.g. toads) and reptiles

Recommendation are made to avoid and mitigate significant ecological impacts including timing of work and implementation of good working practice. Compensatory habitat creation is outlined to achieve No Net Loss of biodiversity while ecological enhancements are recommended to deliver a Biodiversity Net Gain. Standard planning conditions are recommended to secure the measures proposed.

1 Introduction

1.1 BRIEF MHE Consulting Ltd were instructed to undertake an ecological survey and assessment of a proposed residential development of the J Breheny works site, Flordon Road, Creeting St Mary, Suffolk (TM 09471 55528, Figure 1).

Planning approval (Ref: 4188/15) was previously granted (08/04/16) for a hybrid residential (52 units) and commercial (training facility, workshop and car parking) scheme. MHE Consulting Ltd (previously Mill House Ecology) surveyed the site and provided a report1 to support the planning application.

A new application is to be submitted for a residential scheme (19 units: 14 affordable and 5 open market) for the approved training facility, workshop and car parking area. A minor amendment to the approved residential scheme (reduction in units to 51) together with the proposed residential scheme will result in a total of 70 dwellings on site, with 24 affordable units.

The ecological survey and this report are necessary to: • Identify the existing ecological value of the site; • Identify the need for further (e.g. protected species) surveys; • Assess any potential adverse impacts of the proposed development on ecological features of the site or nearby designated sites; • Make recommendations for mitigation (if required); and • Identify opportunities for biodiversity enhancements and, consistent with national and local planning policy, net gains.

This report will be used to develop the proposals as necessary, and to form the basis for the submission of biodiversity information with any planning application. It reflects the sites at the time of the survey and should be reviewed and revised as appropriate.

1.2 SITE LOCATION AND DESCRIPTION The site (Figure 1) comprises the main depot of the J Breheny civil engineering company and includes numerous workshops, storage buildings, and hard standing areas used for the storage of construction material, signage, welfare units etc. (Photos 1 to 6).

Photos of habitats present are provided within Appendix A1.

1 Mill House Ecology (2015) Proposed residential development J Breheny Works Site, Flordon Road, Creeting St Mary, Suffolk. Ecological Appraisal October 2015, unpublished client report

2 Planning policy and legislation

2.1 INTRODUCTION This chapter summarises the key legislation and policies relevant to assessing the biodiversity impacts of the scheme upon habitats and species.

2.2 PLANNING POLICY 2.2.1 National Planning Policy Framework (NPFF) The National Planning Policy Framework was originally published in 2012 and recently revised in February 2019. The document sets out the Government’s planning policies for England and provides guidance on how these policies are expected to be applied. It provides a framework for, and must be taken account of within, locally prepared plans for housing and other development, and is a material consideration in planning decisions.

An overarching objective of the NPPF, which aims to secure net gains, is to contribute to protecting and enhancing the natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.

The full NPPF is available to view online using the gov.uk website: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachm ent_data/file/779764/NPPF_Feb_2019_web.pdf Policies of particular relevance to development and biodiversity include 170, 175, 176 and 177.

170. Planning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan); b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland; c) maintaining the character of the undeveloped coast, while improving public access to it where appropriate; d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures; e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans; and f) remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.

175. When determining planning applications, local planning authorities should apply the following principles: a) if significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused; b) development on land within or outside a Site of Special Scientific Interest (SSSI), and which is likely to have an adverse effect on it (either individually or in combination with other developments), should not normally be permitted. The only exception is where the benefits of the development in the location proposed clearly outweigh both its likely impact on the features of the site that make it of special scientific interest, and any broader impacts on the national network of Sites of Special Scientific Interest; c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists; and d) development whose primary objective is to conserve or enhance biodiversity should be supported; while opportunities to incorporate biodiversity improvements in and around developments should be encouraged, especially where this can secure measurable net gains for biodiversity.

176. The following should be given the same protection as habitats sites: a) potential Special Protection Areas (SPA) and possible Special Areas of Conservation (SAC); b) listed or proposed Ramsar sites; and c) sites identified, or required, as compensatory measures for adverse effects on habitats sites, potential Special Protection Areas, possible Special Areas of Conservation, and listed or proposed Ramsar sites.

177. The presumption in favour of sustainable development does not apply where the plan or project is likely to have a significant effect on a habitats site (either alone or in combination with other plans or projects), unless an appropriate assessment has concluded that the plan or project will not adversely affect the integrity of the habitats site.

2.2.2 Local Plan Adopted local plans provide the framework for development across England, and include policies related to conserving and enhancing the natural environment. Planning policies and supporting documents that are used to plan, deliver and monitor development across the Mid Suffolk District can be found at https://www.midsuffolk.gov.uk/planning/planning-policy/.

2.3 LEGISLATION 2.3.1 Natural Environment and Rural Communities (NERC) Act 2006 Section 40 places a duty on every public body in exercising its functions, to have regard to the purpose of conserving biodiversity; this includes restoring or enhancing populations or habitats. A key purpose of this duty is to embed consideration of biodiversity as an integral part of policy and public-sector decision making. Species and habitats of principal importance in this respect are those published under Section 41 (“S. 41”) of the NERC Act 2006.

2.3.2 Wildlife and Countryside Act 1981 (as amended) Rare and scarce habitats and species are afforded varying levels of protection under the Wildlife and Countryside Act 1981 (as amended) (hereafter “WCA 1981”). Some species and groups are afforded full protection (e.g. Schedule 1 bird species, bats), whilst others receive partial protection (e.g. widespread reptiles). Section 3.1 provides further detail relevant to this scheme. Species afforded legal protection are referred to by their relevant schedule (“Sch.”) within the act, i.e. “Sch. 1” (birds), “Sch. 5” (other animals), or “Sch. 8” (plants).

Invasive plant species such as Japanese knotweed (Fallopia japonica) and giant hogweed (Heracleum mantegazzanium) are listed on Schedule 9 of the WCA 1981. It is an offence to plant or otherwise cause these species to grow in the wild and this includes the development of sites such that the plant colonises land owned by a third party.

2.3.3 The Countryside and Rights of Way (CROW) Act 2000 The CROW Act 2000 strengthened and updated elements of the WCA 1981, and gave a statutory basis to biodiversity conservation, requiring government departments to have regard for biodiversity in carrying out its functions and to take positive steps to further the conservation of listed habitats and species. It strengthened the protection of SSSI and threatened species. Many of its provisions have been incorporated as amendments into the WCA 1981 and some have been superseded by the NERC Act 2006.

2.3.4 The Conservation of Habitats and Species Regulations 2017 The Conservation of Habitat and Species Regulations 2017 (hereafter referred to as the Habitat Regulations 2017) consolidate the Conservation of Habitats and Species Regulations 2010 with subsequent amendments. The Regulations transpose Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (EC Habitats Directive), and elements of the EU Wild Birds Directive, into national law. The 2017 Regulations provide for the designation and protection of ‘European sites’ (Special Protection Areas, SPAs, and Special Areas of Conservation, SACs), the protection of ‘European Protected Species’ (“EPS”), and the adaptation of planning and other controls for the protection of European Sites.

The 2017 Regulations have recently been amended by the Conservation of Habitats and Species Regulations (Amendment) (EU Exit) Regulations 2019, which continue the same provision for European protected species, licensing requirements, and protected areas after Brexit.

Under the Regulations, competent authorities i.e. any Minister, government department, public body, or person holding public office, have a general duty, in the exercise of any of their functions, to have regard to the relevant EC Directives.

2.3.5 Protection of Badgers Act 1992 The Protection of Badgers Act 1992 (hereafter “PBA 1992”) consolidates and improves upon the previous Badgers Act 1973, Badgers Act 1991, and Badgers (Further Protection) Act 1991. Under the PBA 1992 (except when holding a licence to do so) it is illegal for a person to wilfully; kill, injure, take, posses, sell, or otherwise cruelly treat a badger. It is also illegal to dig out, damage, destroy, or obstruct entry to setts

(including by use of dog(s)). Further information on offences, exceptions, and penalties are listed on the PBA 1992 on legislation.gov.uk.

3 Methodology

3.1 INTRODUCTION This report has been produced with reference to relevant guidance, most notably: • Guidelines for Ecological Report Writing (CIEEM, 2017); • Biodiversity – Code of Practice for Planning and Development (BS 42020:20132); • Guidelines for Ecological Impact Assessment in the UK and Ireland (CIEEM, 2018); and • Biodiversity Net Gain: good practise principles for development (CIRIA, CIEEM and IEMA, 2016).

The following sections summarise the approaches used to review existing data, and to undertake appropriate field surveys to scope and inform an Ecological Impact Assessment (EcIA) for the scheme. Where further surveys are considered necessary, this is identified in section 5.

3.2 DESK SURVEY The following data sources were consulted to assess the potential for the application site to support protected or notable habitats/species: • Aerial photos, Ordnance Survey maps, Natural England open source data, and the MAGIC website (http://magic.defra.gov.uk/): These were used to identify habitat types including priority habitats, suitability for particular species/groups, and the locality of nationally and internationally designated sites; and • Historical biological records: species and locally designated site records within 2km of the sites were provided by the Suffolk Biological Information Service (SBIS); and • Ecology surveys undertaken locally and available on the planning portal.

From this exercise, it was concluded that the following legally protected species/groups may be present on the sites and/or land immediately adjacent: • Amphibians including great crested newt (GCN) (Triturus cristatus)3 and reptiles such as grass snake (Natrix helvetica)4; • Mammals including badgers (Meles meles)5 and bats2; • Breeding birds6 including Red and Amber status7 species; and • S. 418 list habitats such as ephemeral/short perennial vegetation and species such as hedgehog (Erinaceus europaeus).

In the context of the setting and nature of the developments, the ‘zone of influence’ of the scheme is considered restricted to habitats on the sites and species within 250m of the site boundaries.

3.3 FIELD SURVEY An initial site walkover was undertaken on the 3rd September 2015 and a further site visit undertaken on the 27th March 2020 to 1) record habitats present, and 2) assess

2 BSI Standards publication BS 42020:2013 Biodiversity – Code of practice for planning and development. 3 GCNs and all species of bats receive full protection under the WCA 1981 and the Conservation of Habitats and Species Regulations (Amendment) (EU Exit) Regulations 2019. 4 Widespread reptiles and amphibians receive partial protection under the WCA 1981. 5 Badgers and their setts are afforded protection by the PBA 1992. 6 All wild birds, their nests and eggs are protected under the WCA 1981 (as amended), level of protection varies per species. 7 The conservation statuses of UK bird species are listed within the Birds of Conservation Concern 4 (Eaton et al., 2015). 8 S. 41 of the NERC Act 2006 lists ‘habitats and species which are of principal importance for the conservation of biodiversity in England’.

the value of the habitats present for protected and notable species. A list of vascular plants and a description of the vegetation was made, including the location and extent of any Schedule 9 (WCA 1981) plants. Photos of the habitats present, and any field signs are provided in Appendix A1.

3.3.1 Habitats and vascular plants The sites were walked with all distinct vegetation and habitat types, and any features of interest identified using the Phase 1 Habitat Survey methodology (JNCC, 2010). Care was taken to record as many species as possible.

3.3.2 Amphibians and reptiles a) Amphibians No ponds exist on site with the nearest ponds P1 and P2 (Photos 7 and 8) located c. 170m (TM 09305 55628) and 330m (TM 09181 55271) to the north-west and south- west respectively of the application site (Figure 2) were assessed (02/06/21) with regards to the suitability for supporting GCNs using the Habitat Suitability Index (Oldham et al., 2000).

The terrestrial habitat suitability of the site for amphibians and reptiles was assessed with respect to refugia and foraging habitat based on their known habitat preferences.

b) Reptiles Habitats on and around the application sites were assessed with respect to the known foraging and refuge habitat preferences of widespread reptile species.

3.3.3 Bats a) Preliminary Roost Assessment Existing buildings were assessed for Bat Roosting Potential (BRP) with reference to the Bat Conservation Trust (BCT) “Bat Surveys: Good Practice Guidelines, 3rd edition” (Collins, 2016). Evidence of roosting bats was recorded if observed.

b) Tree Roost Assessment No trees require felling within the application site.

c) Foraging and commuting habitat Consideration is given to the value of any potential foraging and commuting habitats (i.e. hedgerows, trees, ponds) on the application site (Collins, 2016).

3.3.5 Nesting birds The value of the site was assessed in relation to nesting birds. This was supplemented with field records of birds seen or heard within the site, or nests observed.

3.3.6 Badger The application sites and adjacent habitats were surveyed for evidence of badger activity including setts, day beds, latrines, diggings/snuffle holes, paths/runs, scratching posts, hair, and footprints. Any potential sett found was then assessed for evidence of recent use by badger and classified as per current guidance (Scottish Badgers, 2018).

3.3.7 S. 41 list habitats and species The site was surveyed to determine the presence of any S. 41 habitats such as native species-rich hedgerows. The site’s suitability for S. 41 list species such as hedgehog was assessed based on their habitat preferences.

3.3.8 Non-native invasive plant species The site was inspected for Schedule 9 species such as Japanese knotweed and giant hogweed.

3.4 SURVEY CONSTRAINTS All of the site was accessible for inspection. Botanical surveys are best done in the late spring to summer period, though the areas of grassland on site are managed and likely to not support any notable plants with no basal leaves visible for species such as bee orchid (Ophrys apifera), which are visible over winter.

3.5 SURVEYORS The initial site walkover, building inspection and pond assessments were undertaken by Christian Whiting BSc (Hons) MSc MCIEEM MEECW who has over 20 years’ experience working as an ecologist and holds Natural England (NE) survey licences for bats (2015-14745-CLS-CLS - Bat Survey Level 2, and great crested newts (Class A licence 2015-17633-CLS-CLS).

He is a Registered Consultant (Registration RC089) on NE’s Bat Mitigation Class Licence. He is registered on the NE water vole (Arvicola amphibius) Developers Class Licence CL31 (Intentional disturbance of water voles and damage/destruction of water vole burrows by means of ‘Displacement’) and the Environment Agency’s and IDB’s water vole organisational and class licences respectively. His main areas of expertise are bats, vascular plants, amphibians and reptiles, otter (Lutra lutra) and water vole.

3.6 ASSESSMENT Impacts and effects upon habitats and species are assessed with reference to the CIEEM Guidelines for Ecological Impact Assessment (2018) and are reported in Section 5, based on the baseline conditions reported in Section 4.

The assessment includes potential impacts upon habitats and species during the construction and operational phases of the scheme. It considers positive and negative impacts, their extent, magnitude and duration, frequency and timing, and reversibility.

4 Results

4.1 INTRODUCTION This chapter summarises the results of the desk and field surveys.

4.2 BASELINE ECOLOGICAL CONDITIONS - DESK STUDY 4.2.1 Designated sites Any locally designated sites (e.g. Local Nature Reserves) within 2km and nationally designated sites within 5km of the application site are listed in Table 4.1. No internationally designated sites are located within 13km.

Table 4.1 Relevant designated sites Site name Alderson Lake CWS (Mid Suffolk 105) A140 and A14 Road Verges CWS Chalkeith Road Meadow CWS (Mid Suffolk 147) Creeting St Mary Meadows CWS (Mid Suffolk 143) Creeting St Mary Churchyard CWS (Mid Suffolk 48) Fen Alder Carr CWS (Mid Suffolk 47), LNR Lion Inn Meadow and Chalk Pit CWS (Mid Suffolk 104 River Gipping (Sections) CWS (Mid Suffolk 10) Shrubland Park CWS 143 CWS (Mid Suffolk 38), RNR 145 CWS (Mid Suffolk 169), RNR 157 CWS (Mid Suffolk 168), RNR Needham Lake LNR Barking Woods SSSI Combs Wood SSSI Gosbeck Woods SSSI Lingwood Meadows Earl Stonham SSSI

Locally designated sites Alderson Lake CWS (Mid Suffolk 105) supports a diverse emergent and marginal flora as well as supporting breeding and overwintering birds.

Chalkeith Road Meadow CWS (Mid Suffolk 147) is designated for its chalk grassland and supports notable species such as pyramidal orchids (Anacamptis pyramidalis) and bee orchids (Ophrys apifera). Creeting St Mary Meadows CWS (Mid Suffolk 143) supports wet unimproved pasture and notable plant species including southern marsh orchids (Dactylorhiza praetermissa).

Creeting St Mary Churchyard CWS (Mid Suffolk 48) is of high wildlife value as it supports an unimproved, herb-rich, dry grassland flora characteristic of the sands and gravels of this part of Suffolk. The soils are very drought prone and this is reflected in the flora.

Fen Alder Carr CWS (Mid Suffolk 47) and LNR is owned and managed by Suffolk County Council as a statutory Local Nature Reserve. It consists of a mosaic of habitat ranging from open water and tall fen vegetation to dense alder carr.

Lion Inn Meadow and Chalk Pit CWS (Mid Suffolk 104) is designated for its chalk grassland. The Roman snail (Helix pomatia) (Sch. 5 WCA 1981) is also recorded from the site (not listed on the citation). The site also supports nightingale (Luscinia megarhynchos). The River Gipping (Sections) CWS (Mid Suffolk 10) is designated for its aquatic plants and breeding bird interest.

The 143 CWS (Mid Suffolk 38) and RNR is designated because of its notable floral interest include pyramidal orchids and wild liquorice (Astragalus glycyphyllos). The 145 CWS (Mid Suffolk 169) and RNR is designated because of the presence of wild liquorice. The 157 CWS (Mid Suffolk 168) and RNR is designated because of its chalk flora. Needham Lake LNR is managed by Mid Suffolk District Council and is a valuable recreational site which is used extensively by the general public.

In addition to the LNRs, CWSs and RNRs Park Wood/Causeway Grove is an area of semi-ancient woodland.

Given the features, existing land use and location of the locally designated sites, no significant impacts are anticipated.

Nationally designated sites The Barking Woods SSSI are an inter-related group of ancient woodlands, whose history has been well documented since 1251. The majority of the medieval earth banks remain and are marked by large pollards of oak (Quercus sp) and ash (Fraxinus excelsior). The woodland structure is predominantly coppice-with-standards, composed of a variety of different stand-types. The diverse ground flora is typical of ancient woods and reflects a change in soils from the heavy boulder clay of Priestley and Swingen’s Woods to the chalky sand of Titley Hill Wood.

Combs Wood SSSI is an ancient woodland with a well-developed coppice with standards structure, on boulder clay overlain with variable amounts of sand and loess. The consequent range of soil types has led to the development of a variety of woodland types. Pedunculate oak-hornbeam woodland is predominant, with areas of typical ash- maple woodland, this grading into the heavy soil form of pedunculate oak-hazel-ash woodland where the soils are more acid.

Gosbeck Wood SSSI is an ancient coppice-with-standards site with small additions of well-established secondary woodland. It lies on a plateau of calcareous boulder clay soils with pockets of sand. The wood contains a complex mosaic of stand types and is a good example of the type of ancient woodlands found in central Suffolk. The ground flora is typical of woods of this type and locality and includes several uncommon species.

Lingwood Meadows Earl Stonham SSSI consists of two floristically rich old meadows and is one of the few remaining examples of unimproved grassland in Suffolk. The number of such traditionally managed, herb rich meadows has been greatly reduced in recent decades and remain under threat from changes in agricultural practice. It supports a high number of grasses and herbs.

The application site falls within several SSSI Impact Risk Zones. However, the proposed scheme does not meet any of the listed risk criteria and no significant impacts are anticipated.

4.2.2 Species a) Relevant biological records No protected or notable species records exist for the property site boundary nor within the 250m zone of influence. Table 4.2 identifies species records for within 2km the application site boundary

Table 4.2 Protected/notable species within 2km of the application site

Scientific name Common name Legal /conservation status

Bufo bufo Common toad Sch. 5; S. 41 Rana temporaria Common frog Sch. 5 Triturus cristatus Great crested newt EPS; Sch. 5; S. 41 Anguis fragilis Slow-worm Sch. 5; S. 41 Natrix helvetica Grass snake Sch. 5 Zootoca vivipara Common lizard Sch. 5 Arvicola amphibius Water vole Sch. 5 Erinaceus europaeus Hedgehog S. 41 Lepus europaeus Brown hare S. 41 Meles meles Badger PBA 1992 Micromys minutus Harvest mouse S. 41 Muscardinus avellanarius Hazel dormouse EPS; Sch. 5; S. 41 Pipistrellus pipistrellus Common pipistrelle EPS; Sch. 5 Pipistrellus pygmaeus Soprano pipistrelle EPS; Sch. 5; S. 41 Alauda arvensis Skylark Red Status; S. 41 Cettia cetti Cetti’s warbler Sch. 1 Emberiza citrinella Yellowhammer Red Status; S. 41 Emberiza schoeniclus Reed bunting Amber Status; S. 41 Luscinia megarhynchos Nightingale Red Status Passer domesticus House sparrow Red Status; S. 41 Streptopelia turtur Turtle dove Red Status; S. 41

b) Natural England GCN open source data The nearest GCN record is for a site c. 1.5km to the west of the application site and dates from 2016.

c) Previous ecology surveys A Preliminary Ecological Appraisal and subsequent reptile and botany surveys were undertaken (Robson Ecology, 2019; 2019b) of a proposed commercial and residential site off Flordon Road c. 560m to the south-east of the application site. Small numbers of slow-worm and common lizard were recorded.

4.3 BASELINE ECOLOGICAL CONDITIONS – FIELD SURVEY 4.3.1 Habitats and vascular plants The vast majority of the site (Figure 3) comprises hard standing and buildings (Photos 1 to 4). Some small areas of mown lawn (Photos 2 and 5) exist around the main offices, along with some areas of species poor grassland on previously disturbed ground

(Photo 6). Areas of scrub and woodland (Photos 7 and 8) exist adjacent to the eastern and southern site boundaries along with some discrete areas of ruderal habitat including some areas of bracken (Pteridium aquilinum).

Self-sown species of ash (Fraxinus excelsior), silver birch (Betulus pendula) and oak (Quercus robur) exist on site and amongst the blocks of plantation woodland that screens the site. Some mature trees exist along the western and eastern site boundaries including (Acer pseudoplatanus), Scot’s pine (Pinus sylvestris), alder, white willow (Salix alba), golden willow (S. alba ssp), golden willow (S. alba ssp), and grey poplar (Populus canescens). A line of Leyland cypress (Cupressocyparis x leylandii) exists along the top of the embankment/southern site boundary.

Species present include frequent to locally abundant bramble (Rubus fruticosus agg), scattered broom (Cytisus scoparius), grey willow (S. cinerea), gorse (Ulex europaeus), privet (Ligustrum vulgare) and elder (Sambucus nigra).

Areas of lawn (Photos 2 and 5) exist by the existing office building are dominated by grass species such as creeping red fescue (Festuca rubra), creeping bent (Agrostis stolonifera) and annual meadow grass (Poa annua). Forbs present include common mouse-ear (Cerastium fontanum), yarrow (Achillea millefolium), common storksbill (Erodium cicutarium), common centaury (Centaurium erythraea), smooth cat’s-ear (Hypochaeris glabra), broad-leaved plantain (Plantago major), scented mayweed (Matricaria chamomilla), dove’s-foot crane’s-bill (Geranium molle), creeping buttercup (Ranunculus repens) and dandelion (Taraxacum officinale agg.).

An area of ephemeral/short perennial habitat (Photo 6) existed by the offices in 2015 but much of the habitat has now been replaced with a building and car parking.

Localised areas of ruderal habitat exists on site with common nettle (Urtica dioica), rosebay willowherb (Chamerion angustifolium), mugwort (Artemisia vulgaris), bracken, and occasional teasel (Dipsacus sylvestris).

4.3.2 Amphibians and reptiles a) Amphibians i) Pond suitability With regards to the pond P1 (Photo 7) it was visually assessed on the 5 June 2020 and again on the 8 October 2020 when water levels were very low; and it was likely to have dried during the summer following a period of drought. The owners confirmed the pond did dry during the summer. The pond is heavily shaded predominantly by willow scrub with a small area of water visible c. 10 – 15cm deep and it dries most years (Owners pers. comm.). The significant amount of terrestrial vegetation growing in the pond would confirm this. Some waterfowl were observed, though fish are unlikely given the regular drying of the pond. The pond has an HSI of 0.55 = below average.

Pond P2 (Photo 8) was used historically for irrigating crops for the Alder Carr farm shop. It supports a good depth of water and a range of macrophyte and wetland/marginal plants including hornwort, ivy-leaved duckweed, common reedmace, brooklime, water mint and bittersweet. The pond never dries and supports clear water though it has been surveyed several times by local naturalists and has not supported many amphibians (Owner pers. comm.) and no GCNs.

No GCNs have historically been recorded whilst the pond has supported fish and is likely to still support fish and a HSI of 0.75 was calculated based on the pond likely to support small numbers of fish. As the pond has supported dense numbers of fish in the past having been used as a fishpond by the owners’ children – if this is selected the HSI = 0.53 which equates to below average suitability.

ii) Terrestrial habitat Terrestrial habitat within the application site for amphibians is very poor with the site comprising hard standing and modern buildings (Photos 1 to 4). Ecological studies by Jehle (2000), Jehle and Arntzen (2000), and Malmgren (2002) show that GCNs will ‘preferentially’ move towards the most favourable terrestrial habitat during migration from breeding ponds, with woodland and hedgerow habitats ‘preferred’ over pasture and open habitats.

Areas of ruderal, bracken, trees and scrub (Photos 9 and 10) habitats along the eastern southern site boundaries provide some potential refuge habitat. However, as the underlying soils are free draining, common toad are the species most likely to be present as they are more tolerant of dry habitats.

b) Reptiles Areas of scrub habitat along the bank tops adjacent to but outside of the eastern site boundary adjacent to the approved residential scheme provides potential habitat for common lizard. Areas of potential foraging and refuge habitat is present along the eastern site boundary of the approved residential scheme with logs etc stored which provide refuge and basking habitat for common lizards.

4.3.3 Bats a) Buildings No evidence of roosting bats was recorded in any of the buildings on site during building inspections.

b) Foraging and Commuting Habitat The application site (where new homes are proposed) supports negligible commuting/foraging habitat (Collins, 2016), but trees and scrub adjacent to the application site provide habitat for a range of invertebrates which provide food for bats.

4.3.4 Nesting birds None of the buildings supported any evidence of historical nesting by notable bird species. Areas of scrub and trees along the banks adjacent to the eastern and southern site boundaries and trees by the existing site entrance offer nesting habitat for a range of bird species such as dunnock (Prunella modularis) (Amber Status; S. 41 List), song thrush (Turdus philomelos) (Red List; S. 41 List)., blackbird (Turdus merula) and wren (Troglodytes troglodytes). Areas of scrub beyond the south of the application site provides potential nesting habitat for nightingale.

4.3.5 Badger No evidence of badger (e.g. snuffle holes, runs, latrines, setts) was observed.

4.3.6 S. 41 list habitats and species a) Habitats The application site supports no S. 41 habitats.

b) Species The site supports limited habitat for species, though hedgehog may forage over the lawns and areas of ephemeral/short perennial vegetation.

4.3.7 Non-native invasive plants No non-native invasive species were recorded within the application site boundary. Some butterfly bush (Buddleja sp) plants exist on the embankment along the eastern and southern site boundaries.

4.4 GEOGRAPHIC CONTEXT The geographic context of a feature is a useful consideration within an assessment of impacts. For this report, the geographic frames of reference for the habitats and species present on sites are provided in Table 4.3; values are based upon the criteria in Table A3.1 and expert best judgements.

Table 4.3 Feature value based on geographic context Feature Value Trees and scrub Local Amphibians and reptiles Local Bats Local Nesting birds Local S. 41 habitats and species Local

5 Assessment and recommendations

5.1 INTRODUCTION The following section provides a summary description of the proposed developments, with an assessment of associated impacts and likely significant effects upon biodiversity.

The assessment and recommendations are based on use of the mitigation hierarchy, which in the first instance aims to avoid impacts. Where impacts cannot be avoided, they should be minimised (through mitigation). Only where impacts cannot be avoided or minimised should there be compensation for biodiversity harm.

Ecological enhancements are suggested, and consideration is given to individual as well as overall net gains or losses of biodiversity.

5.2 DESCRIPTION OF PROPOSED DEVELOPMENT Planning permission is being sought for a residential scheme of 19 dwellings at the J Breheny works site (Wincer Kievenaar drawing 5330/PA02/A) where planning permission was granted in 2016 for a training facility, workshop and car parking area as part of a hybrid residential/commercial application. A minor amendment (a separate new application) to the approved residential scheme will reduce the number of dwellings to 51. Together with the proposed residential scheme covered by this report, this will result in a total of 70 dwellings on site, with 24 affordable units.

Works will result in the clearance of the site: predominantly existing hard standing, plus smaller areas of mown lawn, ruderal and a very localised area of scrub habitat. Upon completion of works there will be an increase in the extent of vegetation present in the form of managed lawns.

The assessment and recommendations provide preliminary recommendations for mitigation, compensation and enhancements for the proposed development. They are based on information available at the time of writing (Wincer Kievenaar Drawing No. 5330/PA02/A) and should be updated accordingly as the scheme is subsequently amended.

5.3 FURTHER SURVEYS REQUIRED No further surveys are considered necessary at this time. It is generally advised that subject to no significant change in site management regimes, and dependent on the species present, baseline survey results remain valid for approximately 12 – 18 months (CIEEM, 2019). Exceptions include where mobile species are/may be present, where site management practices cease or change, or where existing guidance indicates otherwise.

5.4 ASSESSMENT OF IMPACTS The EcIA assessment process (CIEEM, 2018) involves: • Identifying and characterising impacts and their effects; • Incorporating measures to avoid and mitigate negative impacts and effects; • Assessing the significance of any residual effects after mitigation;

• Identifying appropriate compensation measures to offset significant residual effects; and • Identifying opportunities for ecological enhancement.

The emphasis in EcIA is on the assessment of ‘significant effects’ i.e. an effect that either supports or undermines biodiversity conservation objectives for ‘important ecological features’ or for biodiversity in general. In broad terms significant effects encompass impacts on structure and function of defined sites, habitats or ecosystems and the conservation status of habitats and species including extent, abundance and distribution.

The ecological features to be subject to detailed assessment in this report are those judged to be important and potentially affected by the project; protected species are included where the development will result in a potential breach of legislation.

5.5 HABITATS AND VASCULAR PLANTS a) Potential impacts Site clearance works will result in losses of discrete areas of ruderal/scrub habitat along the southern and eastern site boundary where some lower embankment may require regrading/removal to create a garden for plot H and car parking spaces. Losses of mown lawn are considered not significant, and will be offset by newly established lawns, but losses of ruderal and scrub will reduce the extent of habitat for associated species.

b) Mitigation Retained scrub and trees on slopes/embankments outside of the application site must be protected from damage with Heras (or similar) fencing during the construction phase.

c) Residual effects With current site plans (in the absence of any detailed site plans and landscaping proposals) there is likely to be a loss of scrub and ruderal habitat, requiring compensation (see Section 5.10).

5.6 AMPHIBIANS AND REPTILES a) Potential impacts Any disturbance of the vegetated embankments where tussocky grassland/ruderal species, scrub and trees exist has the potential to impact any common amphibians (e.g. common toad) or common amphibians such as common lizard, through the injury and/or death of animals using the embankments. In addition, any amphibians dispersing to and from breeding ponds locally could fall into open trenches resulting in entrapment and mortality.

On completion of the development, the use of gulley pots or similar as part of a surface water drainage system can result in the entrapment of amphibians (Muir, 2012) if the gulley pots do not discharge straight into a ditch or pond. The use of silt traps or other impediments can prevent amphibians from getting out.

These impacts would potentially be a significant negative effect upon a small number of animals at the local scale.

b) Mitigation The following measures will be implemented: • Vegetated embankments must be protected from accidental disturbance by using temporary protective fencing as per the recommendations in section 5.5. • Ruderal and scrub vegetation must be cut down in layers as follows: • A first cut to be taken to 250mm above ground level; • After at least 1 hour (preferably overnight), a second cut to ground level. • During the construction phase, trenches will be filled on the same day as excavation where possible. Trenches left overnight will be covered with ply/OSB sheets and any gaps filled with damp sharp sand or mammal ladders installed to let any animals escape; • All open trenches will be inspected prior to filling to ensure no animals (amphibians, reptiles or mammals are present); • Footings and concrete slabs will be poured during the morning to ensure they have hardened off prior to evening to reduce the risk of animals encountering wet concrete; • Any hand mixing of mortar or concrete will be on ply boarding over a tarpaulin which is folded over the boarding at the end of each day to prevent animals coming into contact; • Any excess cement/concrete will be poured into a concrete skip, so it can then set to prevent animals coming into contact. • All building materials will be stored on bare ground or hard standing, or stored off the ground on pallets; • Any waste or spoil stored on site temporarily will be stored on bare/hard ground or in skips to prevent amphibians or reptiles from seeking refuge; • Should any animals be encountered they should be allowed to displace into retained habitat (e.g. boundaries) or carefully relocated. • If any GCNs are encountered works must stop immediately and a qualified ecologist be contacted for advice on how to proceed. • A wildlife friendly drainage strategy must be implemented: 1. Any installed gully pots that do not discharge without impediment straight into a ditch or pond must be situated ≥100mm from roadside; OR 2. A wildlife-kerb9 must be installed adjacent to each gully pot; OR 3. A gully pot ladder10 placed into each gully pot.

c) Residual effects With mitigation implemented direct impacts upon animals will be avoided with no significant residual effect.

5.7 BATS a) Potential impacts i) Roosting bats No impacts anticipated.

ii) Foraging and commuting habitat No areas of commuting/foraging habitat will be lost and therefore no impacts are predicted.

9 e.g. https://www.aco.co.uk/products/wildlife-kerb 10 https://www.thebhs.org/the-bhs-amphibian-gully-pot-ladder

iii) Light disturbance Lighting during the construction and operational phases will result in impacts upon foraging behaviour and increase the risk of predation, which would affect foraging success for a small number of individuals.

iv) Roofing membranes Research has shown bats can become entangled in modern breathable roofing membranes (BRMs) such as Tyvek and other woven membranes, causing injury or death to individuals (Waring et al. 2013). Use of these membranes in the new dwellings may have a negative impact upon bats.

In combination, the above impacts have the potential to result in a significant effect upon the conservation status of bats at a local level.

b) Mitigation i) Roosting bats None required.

ii) Light disturbance Exterior lighting design will be made with refence to published guidance 11 and will consider: 1. Type of lamp (light source): Light levels should be as low as possible as required to fulfil the lighting need. LED lights should be used preferentially, using the warm white spectrum with peak wavelengths >550nm (~3000°K). UV elements and metal halide, fluorescent sources must be avoided; and 2. Lighting design: Lighting should be directed to where it is needed, with no horizontal spillage towards retained trees or scrub. This can be achieved by restricting the height of the lighting columns and the design of the luminaire as follows: • Light columns in general should be as short as possible as light at a low level reduces the ecological impact. • Luminaires with an upward light ratio of 0% should be mounted on the horizontal i.e. with no upward tilt. • If taller columns (> 8m) are required, and as a last resort, accessories such as baffles, hoods or louvres can be used to reduce light spill. • The use of asymmetric beam floodlights (as opposed to symmetric) orientated so that the glass is parallel to the ground will ensure that the light is cast in a downward direction and avoids horizontal spillage; and • PIR movement sensors and timers should be used to minimise the ‘lit time’ (up to 1 minute).

iii) Roofing membranes Breathable membranes should not be used in any roofing works where handmade or reclaimed pantiles or plain tiles are proposed; traditional Type 1F roofing felt or a breathable sarking board (e.g. Hunton Sarket or Pavatex Isolair) should be used. If slates or interlocking pantiles or machine-made plain tiles are used, then a modern BRM could be used if gaps less then 5mm exist between tiles.

c) Residual effects There will be no significant residual effects.

11 https://www.theilp.org.uk/documents/guidance-note-8-bats-and-artificial-lighting

5.8 NESTING BIRDS a) Potential impacts Building demolition and vegetation clearance (e.g. hedgerow and scrub clearance) during the nesting season (1st March to 31st August) may result in the injury or death of nesting birds and damage to active nests and eggs, together with loss of nesting habitat, considered a negative effect at a local scale.

Residential development will ultimately increase predation of birds locally by cats.

b) Mitigation Retained habitats adjacent to the development site will be protected as per section 5.5.

Removal of habitats on site will be carried out outside the nesting bird season. If this is not feasible for any reason, then checks and supervision will be undertaken by a suitably experienced ecologist immediately prior to and during the vegetation clearance.

c) Residual effects With implementation of prescribed mitigation impacts upon nesting birds will be limited. However, there will be a temporary residual negative effect on availability of local nesting habitats without compensation.

5.9 OTHER S. 41 LIST HABITATS AND SPECIES a) Potential impacts Vegetation clearance, ground-breaking and construction activities will result in permanent small losses of potential hedgehog foraging (lawn and ephemeral/short perennial vegetation) habitat, though not considered significant given lawn creation as part of the scheme.

Any disturbance of the vegetated embankments would impact potential hedgehog refuge (including potentially for overwintering), and nesting habitat, with potential entrapment, injury and mortality of individuals due to presence of trenches as well as caustic and building materials. Erection of ecological barriers (e.g. timber panel fencing as proposed along the northern site boundary) would reduce dispersal capability negatively impacting fitness and recruitment rates. Such impacts have the potential to result in negative effects upon animals noted to be using the sites.

b) Mitigation Removal of dense ruderal and scrub habitat should take place in early autumn to avoid impacts upon nesting hedgehog. If clearance is required in the spring to avoid nesting bird issues, advance checks should be undertaken by an ecologist and/or vegetation should be retained to no lower than 300mm above ground level to avoid injury or harm to hibernating hedgehog until temperatures are regularly (six consecutive days/nights) maintained above 6°C.

Open trenches should ideally be covered overnight, or mammal ladders fitted in each corner of footings (e.g. a minimum of 4 per excavation assuming a perimeter footing extends around the outside of the dwelling/s).

During construction, concrete must be poured early in the day or covered with ply boarding or membrane overnight to prevent hedgehog coming into contact. Trenches should be inspected for the presence of any hedgehogs and other wildlife (amphibians, reptile and other mammals) prior to commencing a concrete pour.

The use of close board fencing (as proposed) should be minimised, with native species- rich hedgerows preferable where boundary features are required. If extensive close board fencing is installed, then at least one hedgehog highway12 should be provided at either end of the fencing run with signage.13

c) Residual effects Direct impacts upon hedgehog will be avoided with no significant residual impacts.

5.10 COMPENSATION Loss of any ruderal, trees and scrub habitat must be compensated through some planting up of any gaps along the embankment adjacent to the eastern site boundary as a whole. Gorse and broom should be planted to create cover as well as nectar sources for insects. Scrub planting should be indicated on any landscaping proposals to avoid any tussocky grassland/ruderal habitat as this provides habitat for common amphibians and reptiles.

The loss of bird nesting habitat within existing buildings can be compensated through the provision of nest boxes (Appendix A4) for species such as house sparrow (x 3) terraces to be erected on the exterior of the retained office building, and combined robin and wren (x 6) boxes could be erected on retained buildings and/or suitable trees around the J Breheny site boundary as a whole.

The loss of potential hedgehog overwintering habitat will be compensated for by the creation of a brash/log pile from felled scrub/trees on one of the embankments where dense trees/scrub exist.

5.11 CUMULATIVE EFFECTS The Mid Suffolk District Council planning website was searched on the 31st March 2020 with a 1km buffer dating back a minimum of two years. Refused and withdrawn applications were not considered in relation to cumulative ecological effects. Several minor applications were returned.

Applications considered relevant to the current application are summarised below:

• 4188/15 J Breheny Works Site, Flordon Road, Creeting St Mary: A hybrid residential (52 units) and commercial (training facility, workshop and car parking) scheme was granted planning approval on the 08/04/16. A Biodiveristy Method Statement was provided for the scheme to avoid/mitigate impacts. • DC/19/00301 Land North East Of Flordon Road, Creeting St Mary, Suffolk. Full Planning Application – Erection of a ‘Mixed use Development’ comprising; the erection of 3 detached residential dwellings and garages, the erection of 6 small industrial units (B1), and 1 main industrial unit (B2), all with associated parking, landscaping and boundary treatments. A Preliminary Ecology Appraisal and subsequent reptile and botanical survey were provided in support of the application.

12 https://www.hedgehogstreet.org/help-hedgehogs/link-your-garden/ 13 https://ptes.org/shop/just-in/hedgehog-highway/

• DC/18/04782 The Bungalow, Flordon Road, Creeting St Mary, Ipswich, Suffolk IP6 8NH. Full Planning Application – Erection of 1 No. replacement dwelling and 3 No. new dwellings together with garages, associated works and new vehicular access. Planning permission was granted. Two ecology related conditions were included in the permission for the approved scheme, but no ecology report submitted in support of the application. • 0090/17 The Willows, Flordon Road, Creeting St Mary, IP6 8NH. Application for Outline Planning Permission – Erection of single-storey detached dwelling. No ecology report submitted in support of the application which was approved. • 4617/16 and 1689/16 Land To The Rear Of The Laurels, Flordon Road, Creeting St Mary, IP6 8NH. Application for approval of reserved matters regarding access, appearance, scale, and layout and landscaping following outline approval 1689/16 for the erection of a detached dwelling and garage. No ecology report submitted in support of the application which was approved.

There is no indication from the above applications that there will be any significant cumulative impact with the current application.

5.12 ENHANCEMENT OPPORTUNITIES If mitigation and compensation are implemented as advised, the scheme will result in NNL of Biodiversity. To be consistent with local and national planning policy, development schemes should deliver Biodiversity Net Gain (BNG). To deliver a BNG the following enhancements a minimum of 4 of the 6 proposed enhancements (Table 5.1) should be implemented.

Table 5.1 Enhancement opportunities Feature Guidance 1. Native hedgerows Species-rich native hedgerows or shrubs could be planted and shrubs around the site boundary using a minimum of 6 native species per 30m length from the following list: • Common hawthorn (Crataegus monogyna) • Blackthorn (Prunus spinosa) • Guelder rose (Viburnum opulus) • Field maple (Acer campestre) • Hazel (Corylus avellana) • Hornbeam (Carpinus betulus) • Wild privet (Ligustrum vulgare) • Holly (Ilex aquilinum) • Spindle (Euonymus europaeus) • Wild pear (Pyrus pyraster) • Crab apple (Malus sylvestris) These should be planted in biodegradable tubes to protect from grazing by deer and rabbits. Some hedgerows (e.g. more formal species) such as yew (Taxus baccata), privet (Ligustrum ovalifolium) and box honeysuckle (Lonicera nitida) could be incorporated into the site landscaping to mark property boundaries adjacent to the access road.

2. Small passerine Starling nest boxes (Appendix A4) could be erected on the bird boxes existing office building and/or the new dwellings with exact locations agreed with a suitably experienced ecologist. 3. Integrated swift Fifteen integrated swift bricks14 could be incorporated into nest boxes the walls of 5 of the dwellings and/or existing offices just under the eaves, preferably on the north or east side of the dwelling. Homeowners should be supplied with material and guidance on how to attract an initial colony15. 4. Bat boxes Six bat boxes (Appendix A5) could be erected on suitable mature trees around the site boundary. Wall mounted boxes such as the Schwegler 1FE and the Ibstock integrated box could be installed on/in the walls of some of the new dwellings. They would be best positioned on the east or south facing elevations adjacent to vegetated embankments. 5. Pollen-rich climbers Plant a mixture of wild clematis (Clematis vitalba) and honeysuckle (Lonicera periclymenum) at intervals of 5-10m along new hedgerows or within existing wooded areas around the site boundary to provide nectar sources for pollinator species. 6. Flowering lawns Native species-rich flowering lawns could be established in some of the gardens using either an appropriate seed mixture16 or by laying turf17 which can be mown regularly as a typical lawn.

Peat based composts must not be used for any planting or landscaping in order to preserve existing carbon stores and avoid damage to sensitive habitats.

5.13 CONCLUSIONS With avoidance, mitigation and compensations measures suggested, the scheme will result in No Net Loss of biodiversity, whilst enhancements could be implemented to achieve a BNG in accordance with the National Planning Policy Framework and legislation.

Measures proposed should be secured through appropriate planning conditions as per the British Standard (BS 42020:20131). These could include conditions specific to breeding birds (e.g. BS 42020:201 D.3.2.1) or a Biodiversity Method Statement (e.g. BS 42020:2013 D.2.1) or equivalent document used to detail mitigation, compensation and enhancement implementation and associated monitoring.

14 https://swift-conservation.org/Leaflet%204%20-%20Swift%20Nest%20Bricks%20-%20installation%20%26%20suppliers-small.pdf 15 https://swift-conservation.org/2014-06-21%20swiftcallsinstructions.pdf and https://www.swift-conservation.org/2016-08- 23%20EquipmentListforusingtheMP3versionoftheSwiftCalls.pdf 16 https://wildseed.co.uk/mixtures/view/56 17 https://www.wildflowerturf.co.uk/products/wildflower-turf/species-rich/

6 References

CIEEM (2017) Guidelines for Ecological Report Writing. Second edition. Chartered Institute of Ecology and Environmental Management, Winchester.

CIEEM (2018) Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial, Freshwater, Coastal and Marine. Chartered Institute of Ecology and Environmental Management, Winchester.

CIEEM (2019) Advice Note: on the lifespan of ecological reports and surveys.

CIRIA, CIEEM and IEMA (2016) Biodiversity Net Gain: good practice principles for development.

Collins, J. (ed) (2016) Bat Surveys for Professional Ecologists: Good Practice Guidelines (3rd Edition), Bat Conservation Trust, London.

Eaton, M.A., Brown, A.F., Noble, D.G., Musgrove, A.J., Hearn, R., Aebischer, N.J., Gibbons, D.W., Evans, A. and Gregory, R.D. (2015) Birds of Conservation Concern 4: the population status of birds in the United Kingdom, Channel Islands and the Isle of Man. British Birds 102, pp296-341.

JNCC (2010) Handbook for Phase 1 habitat survey – A technique for environmental audit, JNCC, Peterborough.

Jehle, R. (2000) Terrestrial Habitat Exploitation of Radio-Tracked Crested and Marbled Newts: Implications for Site Protection. Herpetological Journal

Jehle, R. & Arntzen, J. W. (2000) Post-Breeding Migration of Newts (Triturus cristatus and Triturus marmoratus) with contrasting ecologic requirements. Journal of Zoology 251: 297-306. JNCC, (2010). Handbook for Phase 1 Habitat Survey. Peterborough

Malmgren, J. C. (2002) How does a newt find its way from a pond? Migration Patterns after Breeding and Metamorphosis in Great Crested Newts (Triturus cristatus) and Smooth Newts (Triturus vulgaris). Herpetological Journal 12: 29-35

Muir, D. (2012), Amphibians in drains project report summary. Biodiversity News, 59, 16-18.

Oldham, R., Keeble, J., Swan, M. and Jeffcote, M. (2000), Evaluating the suitability of habitat for the Great Crested Newt (Triturus cristatus). Herpetological Journal 10(4), pp. 143-155.

Robson Ecology (2019) Preliminary Ecological Appraisal of Flordon Road, Creeting St Mary, Suffolk. Unpublished client report

Robson Ecology (2019b) Reptile and Botany Survey of Land adjacent to Flordon Road, Creeting St Mary, Ipswich, Suffolk. Unpublished client report

Scottish Badgers (2018) Surveying for Badgers: Good Practice Guidelines. Version 1.

Waring, S., Essah, E., Gunnell, K. and Bonser, R. (2013) Double jeopardy: the potential for problems when bats interact with breathable roofing membranes in the United Kingdom. Architecture & Environment, 1 (1). Pp. 1•13.

Figures

Figure 2 Ponds location plan

Lawn

Vegetated embankment with scrub, trees, ruderal and some bracken

Appendices

Appendix A1 Photos

Photo 1 Existing site access Photo 2 Existing access road and offices

Photo 3 View of the site from the south-east corner of site Photo 4 Portacabins and car parking

Photo 5 Mown lawn Photo 6 View from south-west corner of site

Photo 7 Pond P1 Photo 8 Pond P2

Photo 9 Trees, scrub and on the embankment/slope along Photo 10 View of the site from the north east corner with the southern site boundary trees and scrub growing on the embankment along the southern side of the site

Appendix A2 SBIS data

Appendix A3 EcIA criteria

A3.1 General criteria for geographic context/value

Designation Example

International • SPA, SAC and Ramsar sites and the features that they have been designated for. • A sustainable area of habitat listed in Annex I of the Habitats Directive or smaller areas of such habitat which are essential to maintain the viability of a larger whole. • A sustainable population of an internationally important species e.g. UK Red Data Book (RDB) species or European Protected Species (EPS) of unfavourable conservation status in Europe (e.g. Annex II species: bats, GCNs etc.), of uncertain conservation status or of global conservation concern in the UK BAP.

National • SSSI or a discrete area that meets the selection criteria for designation. • A sustainable area of priority habitat identified included on the S. 41 NERC Act list or smaller areas of such habitat that are essential to maintain the viability of a larger whole. • A sustainable population of priority species (listed under S. 41 of the NERC Act 2006). • A sustainable population of a nationally important species i.e. RDB species not included in above category but which is listed on Schedules 5 or 8 of the WCA 1981 (as amended). Also, sites supporting a breeding population of such species or supplying a critical element of their habitat requirements. • A sustainable population of uncommon or threatened Annex IV EPS species at a UK level. • A nationally scarce species (occurs in 30-100 10km squares in the UK) that has its main UK population within the district.

County • A viable area of habitat identified in the county BAP. • A County Wildlife Site. • A sustainable population of common or non-threatened Annex IV EPS species at a UK level. • A Nationally Scarce species that does not have its main population within the county. • A sustainable population of a BAP species not included in the ‘national’ category above for which a county Action Plan exists.

Local • Individual members of local populations of priority or other nationally/internationally important species which are not in themselves key for maintaining a sustainable population (e.g. individual dog otter passing through area with no holts or resting sites). • Other habitats and species not in the above categories but are considered to have some value at the district/borough level.

Appendix A4 Bird boxes

Appendix A5 Bat boxes

Vincent Pro box

Schwegler 1FE